Exchange of information on request compels cross border disclosure of tax relevant and beneficial ownership information for investigations.

Exchange of information on request requires the requested Party's competent authority to provide tax relevant information regardless of domestic need and, where existing holdings are insufficient, to use all relevant information gathering measures, including witness depositions and authenticated originals as allowable by domestic law. Contracting Parties must have authority to obtain data from banks, financial institutions, nominees, trustees and persons acting in fiduciary capacities, and to disclose legal and beneficial ownership information for companies, collective investment vehicles, trusts, foundations and equivalent entities, subject to a limitation for publicly traded entities when obtaining such information would cause disproportionate difficulties.

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